Key Policy Changes (Effective June 18)
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Expanded App Access
- Permitted Activities: Sports betting, lotteries, fantasy sports, horse racing
- Eligibility: SPA-licensed operators only
- App Limits: Up to 3 digital domains per licensed operator
- Previous Restriction: Only Caixa Econômica Federal (state-owned) apps allowed
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Advertising Integration
- Platforms: Google Play Store + Google Ads
- Requirements:
- Valid SPA license verification
- Compliance with Google’s content guidelines
- Mandatory website link to Play Store listing
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Responsible Gambling Mandates
- Built-in tools required:
- Time limits
- Spending caps
- Self-exclusion options
- Built-in tools required:
Market Impact
- Illegal Market Disruption: Unlicensed operators currently control >50% of Brazil’s online gambling market
- New Opportunities: 200+ licensed operators can now distribute apps (~600 potential new apps)
- Consumer Protection: Safer alternatives to illegal sites with transparency features
Legislative Alignment: Bill PL 2738/2025
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Proposed Requirement
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Purpose
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Timeline
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|---|---|---|
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“Adults Only” ratings
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Prevent minor access
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Pending legislation
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Geo-blocking
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Enforce territorial compliance
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5-day license update window
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User reporting tools
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Enhance consumer protection
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Mandatory for all apps
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Real-time license tracking
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Ensure platform accountability
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Within 5 working days
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Strategic Implications
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For Operators
- Compliance Costs: SPA licensing + Google certification + responsible gambling tools
- Market Access: Direct reach to Android’s 120M+ Brazilian users
- Competitive Edge: Legitimacy over illegal alternatives
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For Regulators
- Market Formalization: Shift from unregulated to controlled environment
- Revenue Growth: Better tax collection from licensed operators
- Enforcement: Google as de facto regulator via app store policies
-
For Consumers
- Safer Options: Licensed apps with built-in protections
- Transparency: Clear identification of legal operators
- Accountability: Formal complaint mechanisms
Global Context
Brazil’s approach mirrors trends in other jurisdictions:
- Italy: Technical integration with ADM systems + €7M license fees
- New Zealand: Limited licenses (15) with harm reduction criteria
- Meta: Pre-approval requirements for gambling ads
Common Threads:
- Licensing as gateway to market access
- Tech platforms as enforcement partners
- Responsible gambling tools as non-negotiable requirements
Future Outlook
- Short-Term: Surge in licensed app submissions to Play Store
- Medium-Term: Bill PL 2738/2025 likely to pass → stricter technical requirements
- Long-Term: Potential market consolidation as smaller operators exit due to compliance costs
Critical Success Factors:
- Effective SPA license monitoring
- Google’s enforcement of certification requirements
- Rapid passage of Bill PL 2738/2025 to close regulatory gaps
This policy represents Brazil’s decisive move toward a regulated digital gambling market, leveraging tech platforms to combat illegal operations while establishing consumer protections aligned with global standards.
